Dear Portfolio Committee on Employment and Labour,

I write to formally object to Clause 1 of the Employment Services Amendment Bill [B16–2026], specifically regarding Clause 2.1(g) of the Memorandum, which amends the definition of a "foreign national" to explicitly exclude recognized refugees and asylum seekers, granting them equivalent employment status to South African citizens and permanent residents. While acknowledging South Africa's constitutional and international humanitarian commitments, this broad exemption creates a critical regulatory loophole that fundamentally undermines the Bill's core objective to regulate non-citizen labor and protect domestic employment opportunities via sectoral quotas. Placing refugees and unverified asylum applicants entirely outside these labor migration controls risks severely straining entry-level and semi-skilled job sectors where local unemployment is highest, while inadvertently incentivizing economic migrants to exploit the asylum system solely to bypass Chapter 3A's workplace restrictions. Therefore, I urge the Portfolio Committee to review Clause 1 to ensure that employment parity is subject to targeted sectoral oversight and restricted strictly to fully adjudicated refugees rather than initial asylum applicants.